Ghent, BelgiumUse Readable text for larger type, or zoom in on the pages.
Platform Council
The notice is not the same thing as an answer
Dear Platform Council,
I am writing in reply to Amadou’s letter from Lille. I do not want to repeat his account; I want to add the question it left with me: what is a notice worth if the money is still out of reach while you try to understand it?
On 7 April, a large marketplace placed a hold on €3,840 due to my business. The balance was meant to arrive in my Belgian bank account that week. On 9 April, I could no longer use the account as usual. An email said there had been an “account integrity review” and that some functions were restricted. It did not say which transaction, document or rule had caused the review. It did not tell me when the review would finish.
I run a small business with two employees. I will not name it or describe what it does. I can say that €3,840 is not an abstract balance for us. It was money we had already earned and had counted on for an invoice and our next payroll. I moved money from my own savings to cover the immediate gap. That kept the week from becoming a crisis, but it did not answer the question of why the hold had happened.
On 10 April, I used the platform’s support channel and asked for three things: the specific reason, the material I could provide to resolve it, and a date by which someone would review the case. I received an automated confirmation. On 14 April, I sent the documents requested in the account notice. I kept copies of the messages and checked with my bank whether an incoming transfer had been rejected. The bank had no transfer to trace. On 22 April, the funds were released. I did not receive a clear explanation of what had triggered the hold or what had resolved it.
Belgium is not a place where a small business can simply pause its obligations while waiting for an unclear review. We still have invoices to pay and filings and contributions to plan for. I called my accountant to check the cash-flow consequences and asked my bank what options were available. Neither could tell me when the platform would release the balance. I was not asking them to decide whether the marketplace was right. I needed someone with authority over the hold to tell me what was happening.
There are already relevant protections in European law. The Platform-to-Business Regulation requires a platform to provide a statement of reasons when it restricts or suspends a business user; it also sets a notice period for terminating the whole service, subject to exceptions.1 That matters. But a reason that arrives after a restriction, or a review with no stated end date, can leave a business unable to act at the moment action matters. A right on paper does not cover every practical gap in notice, review and access to funds.
I support the purpose of the draft Platform Fairness Standard now before the Council. I support written notice, a specific reason, review by a person, and a time limit on payout holds. I am asking the Council to amend the draft so these are connected requirements, not four boxes a platform can satisfy at different times.
What I would amend
Where a platform can give advance notice without creating an urgent risk, it should do so before suspending an account, removing a listing, holding a payout or changing a fee. If it must act first, it should say why and send the specific reason promptly.
The notice should identify the affected action and the relevant transaction, conduct or term, and explain what information the business can provide to seek review. “Account integrity” by itself is a category, not an explanation.
A person should review a timely appeal, acknowledge it within two business days and give a decision within ten business days. If the platform needs longer, it should explain what remains under review and give a new date. An automated confirmation should not count as a human review.
A payout hold should have a stated end date. I would set a default maximum of 30 days, with a documented exception where a legal requirement or a specific, continuing risk makes release impossible. The platform should give written updates and reasons for any extension. A hold should not roll over silently.
The standard should apply the same minimum protections in every country where the platform operates. A small business should not have to guess whether the process changes when its address, customers or bank account are in another country.
I know there are real cases where a platform needs to act quickly: a compromised account, a legal order, or a credible risk to customers. The amendment should leave room for that. But urgency should explain why notice came later; it should not excuse an unexplained process that has no person, deadline or route to appeal.
For my case, the fix would not have prevented a review. It would have changed what I could do during it. I could have understood the allegation, sent the right material, known when to expect an answer and planned around a stated limit on the hold. That is the difference between a platform exercising control and a small business being left to wait without usable information.
Please amend the draft before the Council takes it forward. I support the Standard, but the promise must be operational: a reason that is specific, a person who can review it, and a clock that applies to the money as well as the message.
Elise PeetersCo-author · Platform CouncilGhent, Belgium